Since 2024, money you bring into Thailand from abroad can be taxed here. If you’re setting up a BOI company or planning to live in Thailand on an LTR visa, this rule reaches your personal finances in a way your corporate tax holiday does not. Here’s who it actually hits, and how BOI and LTR change the picture.
A lot of founders come to us thinking the BOI promotion tax break covers everything. It doesn’t. The corporate income tax holiday sits on your company’s promoted profit. Your own money, the salary, dividends, and investment income you earn abroad and then move into Thailand to live on, runs on a completely separate track governed by the Revenue Department.
Below we walk through the residency test, what changed in 2024, a proposal that’s still only a proposal, and exactly where BOI and the LTR visa help and where they don’t.
Key Takeaways
- You’re a Thai tax resident if you spend 180 or more days here in a calendar year. Once you are, Thailand taxes your Thai income plus any foreign income you bring into the country.
- Since 1 January 2024, foreign income you remit is taxable no matter which year you earned it. The old trick of waiting a year before bringing money in no longer works. Income earned before 2024 is grandfathered.
- Your BOI corporate tax holiday is a company-level benefit on promoted-activity profit. It does not shield the foreign income you personally remit. These are two separate tax systems.
- Money you put into the company as capital, whether paid-up share capital or a shareholder loan, is an investment, not personal income, so the remittance tax doesn’t touch it. The salary and dividends the company later pays you are income, and those are taxed.
- The LTR visa is the tool that actually exempts your overseas income from Thai personal tax, and its Highly-Skilled Professionals category adds a flat 17% rate on Thai employment income.
- A proposal to tax residents on worldwide income whether or not it’s remitted, paired with a two-year grace window, is still a draft as of mid-2026. It is not law. Don’t plan around it yet.
- Personal income tax runs progressively up to 35%. Corporate income tax is a flat 20%, or zero on the profit covered by your BOI holiday.
First, Are You Even a Thai Tax Resident?
Everything here turns on one number: 180 days. If you’re physically in Thailand for 180 days or more in a calendar year, the Revenue Department treats you as a Thai tax resident for that year. Stay under that threshold and you’re not, so foreign income you bring in isn’t caught.
For most people running a BOI company, this isn’t a choice you get to game. You’ve moved your business to Thailand, you’re here to run it, and you’ll clear 180 days without trying. So assume you’re a tax resident and plan from there. Being a resident means Thailand taxes two things:
- Your Thai-sourced income, the salary you draw from your Thai company, local dividends, and anything you earn from work performed in Thailand.
- Your foreign-sourced income, but only the portion you bring into (remit to) Thailand.
That second point is that Thailand doesn’t tax your global income the moment you earn it the way some countries do. It taxes foreign income when it lands here. Leave it offshore and, under the current rules, it’s outside the Thai net. Move it in to buy a condo, cover living costs, or fund the company, and it becomes assessable.
Watch the day count. The 180-day test is per calendar year and resets every 1 January. Your residency in the year you arrive and the year you leave can differ from the years in between, which changes how a given remittance is treated. If your move straddles a year end, it’s worth timing it deliberately.
What Actually Changed in 2024
For years, Thailand had a well-known loophole. Foreign income was only taxable if you brought it into Thailand in the same year you earned it. Wait until the next calendar year to remit, and it arrived tax-free. Plenty of expats and business owners simply parked income offshore for twelve months and then moved it in clean.
That’s gone. Two Revenue Department orders closed it:
- Por.161/2566 (issued 15 September 2023): foreign-sourced income of a Thai tax resident is taxable when it’s remitted, regardless of the year it was earned. The same-year timing trick no longer does anything.
- Por.162/2566: a grandfather clause. Only foreign income earned on or after 1 January 2024 is caught by the new reading. Anything you earned and held offshore before that date stays outside the rule, even when you bring it in later.
Both took effect for income earned from 1 January 2024. So the practical dividing line is simple: savings and earnings you built up before 2024 can be remitted without triggering this rule, but income you earn from 2024 onward is taxable in Thailand whenever you choose to bring it in, if you’re a tax resident in the year you earned it.
For a foreign founder, this matters most for the money you live on. Say you keep drawing income from a business or investments back home while you build your Thai BOI company. Every time you transfer a chunk of that into Thailand to fund your life here, that transfer is potentially assessable personal income, taxed on the progressive scale below.
| Tax | Rate | Applies to |
|---|---|---|
| Personal income tax (PIT) | Progressive, 0% up to 35% | Your Thai income plus foreign income you remit; top 35% rate on income over THB4,000,000 |
| Corporate income tax (CIT) | 20% (or 0% under a BOI holiday) | Your company’s net profit |
| LTR Highly-Skilled PIT | 17% flat | Thai employment income for that LTR category |
What Counts as “Remittance”
Remittance just means bringing the money into Thailand. A bank transfer into your Thai account is the obvious case, but the concept is broader than a single wire. In practice it covers moving foreign-sourced funds into the country in a form you can use here.
What the rule keys on is the character of the money, not the mechanics of the transfer. If the funds are foreign income you earned as a tax resident from 2024 onward, remitting them makes them assessable. If they’re pre-2024 savings, or genuinely capital rather than income, the treatment is different. That distinction, income versus capital, and which year it belongs to, is where personal tax planning actually happens, and where it’s easy to get wrong without records to back up your position.
Keep your paperwork. The burden is on you to show what a given transfer is, income or capital, which year you earned it, and whether you were a Thai tax resident then. Bank statements, dividend records, and dated account balances from before 2024 are worth holding onto. If you can’t evidence that money is grandfathered or non-assessable, expect it to be treated as taxable income.
What About the Capital You Put Into the Company?
This is one of the first questions founders ask, and the good news is that it sits on the right side of the income-versus-capital line.
When you fund your BOI company, whether as registered paid-up capital or a shareholder loan, you’re making a capital investment, not earning personal income. The remittance rule taxes foreign-sourced income you bring in for yourself; money you send in to subscribe for shares or to lend to the company is capital, and the company receives it as equity or debt, not as taxable revenue.
It’s also exactly what BOI expects. A foreign-majority promoted company has to bring its registered capital in from abroad, in the investor’s name, into the company’s account, and you show proof of that when you apply for your certificate.
That inbound capital is a normal, expected part of setting up, not a taxable event for you or for the company.
Keep capital and income cleanly separate: this protection only holds if the money genuinely is capital and you can show it. Send it straight from your foreign account into the company as a documented share subscription or loan, and keep the paperwork. Where it gets messy is if foreign income you earned as a tax resident lands in your own pocket in Thailand first and then goes into the company, because at that point it can be your assessable income before it ever becomes capital. And the flip side holds too: what the company later pays you, a salary or a dividend, is income, and that is taxed.
The Worldwide-Income Proposal (Still Just a Proposal)
You’ll see scary headlines about Thailand moving to tax residents on their worldwide income, taxing what you earn abroad whether or not you ever bring it in. This would be a much bigger shift than the 2024 change, because it would remove the “only when remitted” shelter entirely.
As of mid-2026, this is a draft. It is not law. The Revenue Department has floated a reform, reported to pair the worldwide-income basis with a two-year grace window (foreign income remitted within two tax years of being earned would be exempt), but it still has to clear the Cabinet and the Council of State before it could take effect. Nothing has been enacted, and no start date is fixed.
Don’t plan around this yet. Treat the worldwide-income reform as a watch item, not a rule. Restructuring your affairs today for a law that hasn’t passed, and whose grace-window terms could change before it does, is a good way to make an expensive mistake. The current rules, remittance-based with the pre-2024 grandfather, are what apply right now. We’ll flag it here if that changes.
Where BOI and LTR Actually Change the Picture
This is the part founders most often get backwards, so it’s worth being blunt about it.
Your BOI tax holiday does not touch your personal remittances
The BOI corporate income tax exemption is a benefit that belongs to your company, and it applies to one thing: the net profit your company earns from its promoted activity. For the years your holiday runs, that profit is exempt from the 20% CIT, and dividends paid out of that exempt profit are tax-free while the holiday lasts.
That’s a genuinely large benefit, and it’s the core of what we cover in our guide to BOI incentives.
But notice what it covers: company profit. It says nothing about the income you personally earn abroad and bring into Thailand to live on. That foreign income is your personal income, assessed under the Revenue Department’s rules, on the progressive PIT scale, exactly like any other tax resident.
Your promotion certificate gives you no shield there. A founder can run a company that pays zero corporate tax and still owe personal income tax on the money they wire in from a foreign salary or foreign investments. Two different taxes, two different rulebooks.
The LTR visa is the tool that reaches your personal foreign income
If you want relief on the personal side, the instrument for that is the Long-Term Resident (LTR) visa, also administered by the BOI.
LTR holders get an exemption on overseas income, which is precisely the gap the corporate holiday leaves open. It targets the foreign salary, dividends, and other overseas earnings you remit, the money the 2024 rule would otherwise tax.
There’s a second benefit worth knowing if you’ll draw a Thai salary. The LTR’s Highly-Skilled Professionals category comes with a flat 17% personal income tax rate on Thai employment income, well below the 35% top marginal rate.
For a founder who qualifies and pays themselves a meaningful salary from a targeted-sector role, that alone can be worth structuring around.
So the clean way to think about it: run your operating company through BOI promotion for the corporate tax holiday, land ownership, and easier work permits; hold an LTR visa personally for the overseas-income exemption and, if you qualify, the 17% flat rate. They solve different problems, and used together they cover both the company and the founder.
The exemption rides on the visa, not the promotion. If you hold an LTR and later lose eligibility or switch to a different visa, the overseas-income exemption goes with it, and your remittances fall back under the standard remittance rule. Keep the visa condition in view when you plan long-term.
What to Do About It
You don’t need to panic, but you do need to plan before you move large sums. A few things are worth getting straight early:
- Know your residency each year. Track your days. Whether you cross 180 decides everything, and it can flip in your arrival and departure years.
- Separate your pre-2024 money. If you have savings built up before 1 January 2024, keep them in identifiable accounts with dated records so you can remit them cleanly under the grandfather rule.
- Decide the BOI-plus-LTR split deliberately. Work out early whether you’ll rely on a Thai salary (where the LTR 17% rate helps) or on remitted foreign income (where the LTR overseas-income exemption helps), because that shapes how you pay yourself.
- Get personal tax advice, not just corporate. The firm setting up your BOI company is focused on the company. Make sure someone is also looking at your personal remittances, because nobody’s promotion certificate covers those.
The founders who get caught out are the ones who assumed BOI meant “no tax” full stop and moved a year’s worth of foreign income into Thailand without thinking about it. The ones who do well treat the company and the person as two separate tax questions from day one.
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